Revised Central Bank-AMLA Guidelines - Anti-Money Laundering ...

AML/CFT GUIDELINEISSUED BY THECENTRAL BANK OF BARBADOSIN CONJUNCTION WITH THE ANTI-MONEY LAUNDERING AUTHORITYMAY 2011iv) As ordering financial institution, batch transfers that include cross-border transfers may betreated as domestic wire transfers, provided that the requirements applicable to domestictransfers are met.v) Where it acts as an intermediary financial institution, the licensee should ensure that alloriginator information from cross-border transfers of any amount, remain with the relateddomestic transfers. Where difficulties arise in maintaining the information, then allinformation received from the ordering financial institution should be retained for no lessthan five years in accordance with Section 18 of the MLFTA.vi) Where it acts as the beneficiary financial institution, the licensee should apply a risk-basedsystem to the review of transfers for complete originator information and the reporting ofunusual or suspicious activity.The requirements are not applicable to the following types of payments:i) Any transfer that flows from a transaction carried out using a credit or debit card so long asthe credit or debit card number accompanies all transfers flowing from the transaction.However, when credit or debit cards are used as a payment system to effect a moneytransfer, the necessary information should be included in the message; andii) Financial institution-to-financial institution transfers where both the originator and thebeneficiary are financial institutions acting on their own behalf.Where a relationship is deemed high risk e.g. located in a high-risk jurisdiction, further to standarddue diligence, a licensee should undertake a more detailed understanding of the:i) AML/CFT programme of the respondent bank and its effectiveness;ii) Review effectiveness of the respondent’s group programme;iii) Respondent’s owners, director and senior managers; andiv) Ownership structure.7.5 Reduced Customer Due DiligenceAs discussed in Section 6.1, the licensee’s policy document should clearly define the riskcategories/approach adopted and associated due diligence, monitoring and other requirements. Alicensee may apply reduced due diligence to a customer provided it satisfies itself that thecustomer is of such a risk level that qualifies for this treatment. Such circumstances are set outbelow:i) Where an application to conduct business is made by:a. An entity licensed under the IFSA or FIA;b. An entity registered under the Securities Act or the Mutual Funds Act;c. An entity licensed under the Insurance Act or Exempt Insurance Act;d. An entity licensed under the Cooperatives Society Act, Friendly Societies Act orAnti-Money Laundering/Combating Terrorist Financing Guideline May 2011 23Bank Supervision DepartmentCENTRAL BANK OF BARBADOS